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| | [No title] |
 | | The shareholder's election year is the taxable year of the shareholder for which it made the section 1295 election. | | | A shareholder of an unpedigreed QEF that is a CFC for the taxable year of the PFIC for which the shareholder makes the section 1295 election may make the deemed dividend election provided the shareholder held stock of that PFIC on the qualification date. | | | The shareholder must attach a schedule to Form 8621 that demonstrates the calculation of the shareholder's pro rata share of the post-1986 earnings and profits of the PFIC that is treated as distributed to the shareholder on the qualification date pursuant to this section. |
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http://www.irs.gov/pub/irs-regs/td8701.txt
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| | [No title] |
| | Shareholder's election year is the taxable year of the shareholder for which it made the section 1295 election. | | | The shareholder also must file amended returns for the taxable years that follow the retroactive election year in which the foreign corporation is a PFIC and a QEF to report the section 1293 inclusion for each of these years, and pay the resulting tax and section 6621 interest. | | | Although such a shareholder may not make a retroactive election, the shareholder may be able to attain certain benefits associated with a retroactive election by making a section 1295 election for the current year together with a purging election under section 1291(d)(2). |
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http://sdc.qai.irs.gov/pub/irs-regs/td8750.txt
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| | Summary of U.S. Tax Rules |
| | How taxed: the U.S. shareholders of a CFC are taxed as if the CFC were a pass-through entity. | | | U.S. shareholders are defined as any shareholder or group of shareholders who are U.S. citizens or residents who - individually or together - own more than 50% of the total combined voting power OR more than 50% of the total value of a foreign corporation. | | | How taxed: the U.S. shareholders include as gross income their share of the foreign personal holding company income that remained undistributed in the corporation. |
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http://www.incorporateoffshore.org/Offshore/offshore-tax-rules.htm
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| | Tax Implications of a S-corporation |
| | A shareholder's basis in his stock is generally its aggregate purchase price, plus the amount of any capital contributions he has made, increased by his share of the corporation's income, and reduced by his share of its losses and any distributions made to him by the corporation to the extent that they are nontaxable. | | | Corporate income is passed through to the shareholders who are required to pay the tax on that income whether or not it is distributed to them. | | | In addition, items which may be separately treated by the shareholders, such as items of tax preference, are separately passed through to the shareholders and reported by them on their individual returns, subject to the general rules affecting such items applicable to the shareholders. |
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http://www.nobfi.com/nevada-corporations/nevada-tax-implications-sc.htm
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| | tax preparation,tax audits,IRS settlement,tax preparation,taxes information |
| | Advantage of this business entity is that the shareholder is taxed at the individual level on their proportional ownership interest of corporate profits. | | | An S corporation is a C corporation with flow through tax benefits directly to the individual shareholder on their proportional ownership interest of corporate profits.. | | | In addition, shareholder's may be double taxed on profits they receive which are characterized as dividends. |
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http://www.reducemytaxes.com/corporations_one.htm
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| | Form 1120S Schedule K-1 Instructions |
| | If you are a calendar year shareholder in a fiscal year 1998—99 corporation, enter these amounts on the corresponding lines of the tax form in use for 1999. | | | When applicable, the passive activity limitations on losses are applied after the limitations on losses for a shareholder's basis in stock and debt and the shareholder's at-risk amount. | | | Because each shareholder decides whether to make the election under section 59(e), the corporation cannot provide you with the amount of the adjustment or tax preference item related to the expenses listed on line 16a. |
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http://www.seidmancpa.com/irsfiles/1120sk1ins.htm
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| | US Taxation of Offshore Entities |
| | Under these rules, a U.S. shareholder of a CFC is required to include in their gross income for the tax year the amount of accumulated earnings of the CFC which are invested in "excess passive assets." Section 951(a)(1)(C). | | | The U.S. shareholders of a CFC are also taxed on their pro rata share of any investment made in U.S. property by the CFC during its tax year. | | | FPHC income is passive investment income, such as interest, dividends, rents, annuities and royalties (except active business computer software royalties), and income from the use of corporate property by a 25 percent or more shareholder, or from personal services rendered under a contract by a 25 percent or more shareholder. |
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http://www.diloffshore.com/lib_taxation.htm
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| | CPA Journal Online |
| | Taxpayers who were confidently creating passive activity income by renting property to their closely held C corporations suddenly found their passive income generator (PIG) had become a pig in a poke when the Treasury reversed its position in October 1994 and declared the income to be nonpassive. | | | Following the proposed regulation for 1993 and 1994 leaves the taxpayer with an expired temporary regulation allowing passive income generation by a shareholder renting property to a closely held C corporation, followed immediately by an equally authoritative proposed regulation that is silent on the issue. | | | The Treasury had always prohibited taxpayers from generating passive income by renting property to their own passthrough entities such as partnerships or S corporations in which they materially participate. |
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http://www.nysscpa.org/cpajournal/1996/JAN96/f440196.htm
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| | From The Tax Adviser |
| | The shareholder must have a reasonable expectation that he or she will generate a profit from the sale and leaseback, considering both the value of the property when it is eventually sold and the rent received during the lease term. | | | However, whether the shareholder may characterize the rental income as passive depends on both his or her ownership interest in the corporation and material participation in its business. | | | One strategy that could provide tax and financial advantages to both a corporation and its controlling shareholder is a sale and leaseback of real property in which the corporation sells real estate with a building on it to the shareholder, who, in turn, leases both back to the company. |
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http://www.aicpa.org/pubs/jofa/may2001/ftta.htm
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| | Community Banking: Subchapter S, one year later |
| | The bill would lower the federal tax rates paid by S corporation shareholders to no more than 34% when the S corporation reinvests its earnings in the business, or when the earnings are distributed to the shareholders for the purposes of making tax payments. | | | As a general rule, each 2% shareholder of a Subchapter S corporation is treated as a partner for federal tax purposes. | | | The tax laws impose a corporate-level "sting" tax on any amount of "passive investment income" that exceeds 25% of the gross receipts of the S corporation. |
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http://www.banking.com/aba/community_0498.asp
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| | [No title] |
| | As we have stated: passive institutional investors generally invest funds on behalf of others, play passive investment roles, and are generally prohibited either by law or by fiduciary duties from becoming involved in the operation or control of the companies in which they invest. | | | Clearly, passive investors continue to face multiple constraints on their ability to become directly involved with the management and operations of the firms in which they invest, including statutory and regulatory restrictions as well as fiduciary obligations. | | | For example, under the current broadcast attribution rules, passive investors are subject to a higher voting stock attribution benchmark, since these parties are subject to fiduciary and other restraints on their exercise of influence over licensees and are, by their nature, principally concerned with investment returns rather than direct influence over the licensee. |
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http://www.fcc.gov/Bureaus/Mass_Media/Orders/1999/fcc99207.txt
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| | Chapter 11 - S Corporations - |
| | Passive investment income cannot exceed 25% of gross receipts for 3 consecutive tax years. | | | Result is treatment as compensation income to the shareholder, with deduction as compensation for the corporation. | | | If the S election terminates - shareholder has “one year post-termination transition period” in which to increase basis and deduct the loss, or loss is lost. |
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http://www.abacus.fau.edu/urquhart/taxchapter11.htm
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| | Passive foreign investment company taxation |
| | If this election is made by the US shareholder, the shareholder must report as income his or her pro rata share of the earnings and capital gains of the QEF for the taxable year. | | | The income is passed through to the shareholders in proportion to their holdings and reported to the IRS on a form 1099 by the mutual fund. | | | In some cases, a US person may be able to utilize a foreign variable annuity or variable life insurance contract to invest in foreign mutual funds, but the tax treatment will be based on the rules for investments in annuities or life insurance rather than for investments in the underlying stocks or mutual funds. |
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http://www.rpifs.com/offshoretax/otpfic.htm
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| | Bergman, Horowitz and Reynolds, P.C. |
| | Upon a sale of CFC shares, U.S. shareholders are required to treat gain realized as ordinary income to the extent of their pro rata shares of the CFC's accumulated net earnings and profits. | | | A shareholder who makes the new "Mark to Market" election will recognize ordinary income to the extent the fair market value of the stock exceeds its basis at the end of the shareholder's taxable year. | | | For purposes of determining the proportion of assets held for the production of passive income, the assets of a non-publicly traded PFIC which is also a CFC are valued using the adjusted basis instead of their fair market value. |
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http://www.taxlawyers.com/world_taxalert/int_w98.htm
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| | Legislation 1 |
| | Shareholder basis not increased by income derived from cancellation of S corporation's debt. | | | (a) IN GENERAL- Section 1366(a)(1) (relating to determination of shareholder's tax liability) is amended by inserting `but not including income excludable from gross income under section 108' after `tax-exempt income'. | | | Exclusion of investment securities income from passive income test for bank S corporations. |
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http://www.s-corp.org/ASP/Products/product_5_1.asp
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| | revrul95-5 |
| | Section 1.469-2T(e)(3) provides that, in the case of a sale, exchange, or other disposition of an interest in a passthrough entity (a partnership or an S corporation), the amount of the seller's gain from each activity in which such entity has an interest is determined under that section for purposes of section 469. | | | Individual B is a shareholder of S corporation X. X has no accumulated earnings and profits. | | | Section 469(a) disallows the passive activity loss for the tax year of individuals, estates, trusts, and certain corporations. |
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http://www.taxlinks.com/rulings/1995/revrul95-5.htm
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| | Item 10. Additional Information (cont.) |
| | The U.S. Shareholder generally will be allowed an ordinary deduction for the excess, if any, of the adjusted basis of the PFIC stock over its fair market value as of the close of the taxable year, or the amount of any net mark-to-market gains recognized for prior taxable years, whichever is less. | | | A U.S. Shareholder’s adjusted tax basis in the ordinary shares generally will be adjusted to reflect the amounts included or deducted under the mark-to-market election. | | | Under such election, the U.S. Shareholder will include in income each year any excess of the fair market value of the PFIC stock at the close of each taxable year over the U.S. Shareholder’s adjusted basis in such stock. |
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http://www.checkpoint.com/corporate/ir/20f/38.htm
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| | 1995 ANNUAL REPORT |
| | To the Board of Directors and Shareholders Berkshire Hathaway Inc. We have audited the accompanying consolidated balance sheets of Berkshire Hathaway Inc. and subsidiaries as of December 31, 1995 and 1994, and the related consolidated statements of earnings, and cash flows for each of the three years in the period ended December 31, 1995. | | | They would be sold by brokers working for big commissions, would impose other burdensome costs on their shareholders, and would be marketed en masse to unsophisticated buyers, apt to be seduced by our past record and beguiled by the publicity Berkshire and I have received in recent years. | | | Available-for-sale securities are stated at fair value, with unrealized gains and losses, net of tax, reported in a separate component of shareholders' equity. |
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http://www.berkshirehathaway.com/1995ar/1995ar.html
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| | Collective Moral Responsibility [Internet Encyclopedia of Philosophy] |
| | Central to this nexus, shareholders hire managers and directors in order to maximize their financial investments, and these agents for the shareholders are themselves also motivated by various, chiefly financial, incentives. | | | In fact, many if not most boards are rather passive and routinely authorize all of the decisions and the policies which top management proposes with little or no scrutiny. | | | An outside director is a director who is neither a manager nor a shareholder in the corporation. |
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http://www.iep.utm.edu/c/collecti.htm
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| | passivenev |
| | As you should be able to see, using passive "C" corporations neatly sidesteps "anti-Nevada" argument number [3], which for right now we assume to be true; for if a corporation earns no income and pays no dividends, shareholders identities cannot be exposed via subpoenaed tax returns, as shareholder returns would show no dividend payments received. | | | Stock ledgers containing a list of shareholders can quite lawfully be held offshore, outside of the U.S. governments jurisdiction and political influence [Outer Mongolia anyone?] all listed shareholders could be foreigners living outside of U.S. jurisdiction overseas or shares are simply never issued. | | | The bank account of a passive corporation should also be no -interest checking for the same reason. |
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http://www.onebornfree.com/apg2warn.htm
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| | MDP Interactive > Cutting Edge Current |
| | For purposes of calculating eligible shareholders, family members may elect to be deemed one shareholder. | | | In addition, under the Act, dividends received by an individual shareholder from domestic and qualified foreign corporations generally are taxed at the same rates that apply to capital gains. | | | The regulations provide similar loan and economic benefit rules for split-dollar life insurance arrangements between family members or other parties, such as corporations and their shareholders. |
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http://mdpacademy.com/Special_Bulletins.html
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| | INTOSAI WGAP: The role and responsibility of the State as minority shareholder in a privatised business (Hungary) - ... |
| | The majority of nearly 2000 state owned or municipality owned enterprises were sold (these no longer fall under the responsibility of the state as an owner); 162 companies continue to work with majority state holding while in 102 companies the state is in a minority shareholder position (under 25%). | | | INTOSAI WGAP: The role and responsibility of the State as minority shareholder in a privatised business (Hungary) - Paper for the 6th meeting, Warsaw, 5-6 October 1999 | | | INTO SAI Working Group on the Audit of Privatisation |
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http://www.nao.org.uk/intosai/wgap/6thmeetinghungary.htm
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| | Cooperative - Encyclopedia.WorldSearch |
| | A cooperative (also co-operative or co-op) comprises a legal entity owned and democratically controlled by its members, with no passive shareholder s. | | | Unlike a union, a cooperative may assign different numbers of vote s to different members; typically a cooperative is governed proportionally according to each member's level of economic interest in the cooperative. | | | Home - Link to Us - Add to favorites |
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http://encyclopedia.worldsearch.com/cooperative.htm
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| | Strategic management Details, Meaning Strategic management Article and Explanation Guide |
| | They also developed techniques for estimating the lifetime value of a loyal customer, called Customer lifetime value (CLV). | | | This has come to be known as the loyalty effect after Reicheld's book of the same name in which he broadens the concept to include employee loyalty, supplier loyalty, distributor loyalty, and shareholder loyalty. | | | There were many situations in which non-confrontational approaches were more appropriate. |
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http://www.e-paranoids.com/s/st/strategic_management.html
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| | Recent Faculty Scholarship |
| | When is a Principal Charged with an Agent’s Knowledge? | | | Shareholder Nominations of Directors, 78 Australian Law Journal 311 (2004) | | | Corporate Litigation in the U.S. and U.K., 51 American Journal of Comparative Law 229-35 (2003) (reviewing A.J. Boyle, Minority Shareholders' Remedies (2002)). |
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http://www.law.duke.edu/fac/facpub.html
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| | Energy Solutions: Staff |
| | His efforts contributed to the successful close of these programs in 1998 with $11.8 million dollars in shareholder earnings. | | | She was also responsible for providing guided tours of the facility and assisting with workshops, which entailed educating visitors about the various solar and wind power systems, the ecological design of the site, and the passive solar retail building. | | | As technical and administrative lead on energy efficiency for his department, Mr. |
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http://www.energy-solution.com/staff.html
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| | Definition of passive |
| | , inactive -- lacking in energy or will; "Much benevolence of the passive order may be traced to a disinclination to inflict pain upon oneself"- George Meredith | | | -- the voice used to indicate that the grammatical subject of the verb is the recipient (not the source) of the action denoted by the verb; "`The ball was thrown by the boy' uses the passive voice"; "`The ball was thrown' is an abbreviated passive" | | | , peaceful -- peacefully resistant in response to injustice; "passive resistance" |
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http://www.dictionarydefinition.net/passive.html
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